Suzanne Richer

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Challenged with classification? Classifying the same product differently in one or more countries? Uncertain as to when a “kit” is a “kit for customs purposes” or when to classify a part with the machine and when not to?

The Harmonized System (HS) is a global number, to 6-digits, that drives the duties, fees and taxes of a product upon importation, in addition to applicable protective measures (i.e.: antidumping). In addition, the HS number is the basis of many free trade agreement qualification processes. So why do so many companies raise their customs risk and classify some products differently when operating in more than one country?

Claiming preferential treatment under any free trade agreement is fairly easy. Statements on the commercial invoice or accompanying certificates at the time of import are enough for your customs broker to claim the lower duty rate on your behalf. Proving eligibility of a reduced duty claim is quite the opposite, whether you are an importer, exporter, or the producer of the good.

Customs and Border Protection (CBP) has long been an advocate of transparency and risk reduction in global supply chains through the Customs-Trade Partnership against Terrorism (C-TPAT), a voluntary cargo security program for global transactions. Since its inception in 2002, C-TPAT has been the basis of how the government manages and monitors cargo security.

The security threats the nation faced in 2002 are vastly different from today’s security and terrorism concerns. Each day brings a new cargo security concern based on more complex supply chains, and greater risk of data breaches and cyber-attacks. Changing players in company supply chains can also impact cargo security and put companies at risk.

To address today’s risk, CBP has released a more comprehensive cargo security program, with the support of the trade, to mirror the threats now prevalent in global supply chains. The newly released Minimum-Security Criteria (MSC) replace the previous Minimum-Security Guidelines (MSG), changing the landscape of the program for current members, and future volunteers to the program.

In a further indication that U.S. trade policy toward China has stiffened, the Trump Administration has initiated a punitive tariff action against China under Section 301 of the Tariff Act. Section 301 empowers the White House to impose additional import tariffs on the products of countries who maintain discriminatory policies against U.S. products and services.

The importing community is reacting to the recently announced tariff increases based on a recommendation from the United States International Trade Commission. This led to President Trump’s move to add a 30% tariff on solar cells and up to 50% for imported washing machines. The tariffs on the solar cells would decrease over a four-year period.

The President is using Section 201 of the Trade Act of 1974, the so-called “escape clause” to take this action. This rarely used statutory provision empowers the President to grant temporary import relief, by raising import duties or imposing non-tariff barriers on goods entering the United States that injure or threaten to injure domestic industries that produce similar goods.

Duty Drawback represents one of Customs’ most long-standing benefits to firms, as it offers companies a refund of up to 99% of taxes, duties and fees paid when imported merchandise is exported or destroyed within certain timeframes. The concept is simple – match your import entry documents with the corresponding export docs, file for expedited payment processing, and voila! Money will flow into your bank account.

As simple as it seems, drawback regulations are among the most complicated, and it is estimated that $2.8 billion dollars is left unclaimed by companies eligible for refund. Enter Amber Road’s Global Trade Academy – after attending the unique 3-day Duty Drawback Certificate Program, attendees have succeeded in securing incredible refunds for their firms.

One great success story is that of Tammy Anderson, Logistics Supervisor with an electronics firm, who in less than one year was able to secure $1.3 million dollars from her drawback program.

On June 21st, Amber Road in conjunction with American Shipper broadcasted a webinar entitled, Framing the Total Landed Cost Picture. Our presenters, Suzanne Richer and Phanibhushan Reddy from Amber Road, received several questions throughout the webinar, but unfortunately we did not have time to address them all during the live broadcast. We have compiled their answers into a Q&A document - here is a preview:

Earlier this year, Amber Road’s Global Trade Academy broadcasted a webinar, Trade Compliance Survival Guide. I received several questions throughout the webinar, but unfortunately, I did not have time to address them all during the live broadcast. I have compiled some of my answers into a Q&A document - here is a preview:

As the price of oil drops, companies need to reconsider their cost-saving strategies and how to manage global supply chains for bottom line impact. Typically, companies focus their efforts only on how they can drive costs down within their supply chain, without considering how their import/export compliance team can improve value.